KPMG PPT - Tax Executives Institute, Inc.

Unified Loss Rules
Attribute Reduction Rule
► Prevent group from recognizing more than one loss with respect to
a single economic loss.
► If there is a stock loss that reflects a subsidiary’s tax attributes,
► The stock loss is allowed, but the subsidiary is required to reduce
its tax attributes;
► Election available to reduce stock basis or reattribute certain
attributes.
► Rule does not apply if aggregate attribute reduction is less than 5
percent of the aggregate value of the transferred shares.
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